Note: The degree of the offense
depends on the value of the slugs. See § 53a-144 (first degree: exceeds $100);
§ 53a-145 (a) (2): does not exceed $100).

The defendant is charged [in count __]
with unlawfully using slugs in the first degree. The statute defining this
offense reads in pertinent part as follows:

a person is guilty of unlawfully
using slugs in the first degree when (he/she) (makes / possesses / disposes of)
slugs with intent to enable a person to insert or deposit them in a coin machine
and the value of such slugs (exceeds / does not exceed) one hundred dollars.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - Made, possessed or
disposed of slugsThe first element is that the
defendant (made / possessed / disposed of) slugs. "Slug"
means an object or article which, by virtue of its size, shape or any other
quality, is capable of being inserted or deposited in a coin machine as an
improper substitute for a genuine coin, bill or token. <See
Possession, Instruction 2.11-1.>

Element 2 - IntentThe second element is that (he/she)
(made / possessed / disposed of) slugs with the intent to enable a person to
insert or deposit them in a coin machine. "Coin
machine" means a coin box, turnstile, vending machine or other mechanical or
electronic device or receptacle designed (A) to receive a coin or bill or token
made for the purpose, and (B) in return for the insertion or deposit thereof,
automatically to offer, to provide, to assist in providing or to permit the
acquisition of some property or some service.

A person acts "intentionally"
with respect to a result when (his/her) conscious objective is to cause such
result. <See
Intent: Specific, Instruction 2.3-1.>

Element 3 - ValueThe third element is that the value of
such slugs (exceeded / did not exceed) one hundred dollars. "Value"
of a slug means the value of the coin, bill or token for which it is capable of
being substituted.

Conclusion

In summary, the state must prove
beyond a reasonable doubt that 1) the defendant (made / possessed / disposed of)
slugs, 2) (he/she) had the intent to enable a person to insert or deposit them
in a coin machine, and 3) the value of the slugs (exceeded / did not exceed) one
hundred dollars.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of
unlawfully using slugs in the (first / second) degree, then you shall find the
defendant guilty. On the other hand, if you unanimously find that the state has
failed to prove beyond a reasonable doubt any of the elements, you shall then
find the defendant not guilty.